EN BANC

RE: PETITION FOR RADIO

AND
TELEVISION
COVERAGE
OF
THE
MULTIPLE MURDER CASES
AGAINST
MAGUINDANAO
GOVERNOR
ZALDY
AMPATUAN, ET AL.,

x ----------------------------------- x
RE: PETITION FOR THE
CONSTITUTION OF THE
PRESENT
COURT
HANDLING THE TRIAL OF
THE MASSACRE OF 57
PERSONS, INCLUDING 32
JOURNALISTS,
IN
AMPATUAN, MAGUINDANAO
INTO A SPECIAL COURT
HANDLING
THIS
CASE
ALONE FOR THE PURPOSE
OF ACHIEVING GENUINE
SPEEDY TRIAL and FOR THE
SETTING UP OF VIDEOCAM
AND
MONITOR
JUST
OUTSIDE THE COURT FOR
JOURNALISTS TO COVER
AND FOR THE PEOPLE TO
WITNESS THE TRIAL OF
THE DECADE TO MAKE IT
TRULY
PUBLIC
AND
IMPARTIAL
AS
COMMANDED
BY
THE
CONSTITUTION,

A.M. No. 10-11-5-SC

A.M. No. 10-11-6-SC

Present:
CORONA,* C.J.,
CARPIO,
CARPIO MORALES,
VELASCO, JR.,
LEONARDO-DE CASTRO,
BRION,
PERALTA,
BERSAMIN,
DEL CASTILLO,
ABAD,
VILLARAMA, JR.,
PEREZ,
MENDOZA, and
SERENO, JJ.

Promulgated:
June 14, 2011

x ---------------------------------x
RE: LETTER OF PRESIDENT
BENIGNO S. AQUINO III FOR

A.M. No. 10-11-7-SC

THE
LIVE
MEDIA
COVERAGE
OF
THE
MAGUINDANAO MASSACRE
TRIAL.
x----------------------------------------------------------------------------------------x

RESOLUTION
CARPIO MORALES, J.:
On November 23, 2009, 57 people including 32 journalists and media
practitioners were killed while on their way to Shariff Aguak in Maguindanao.
Touted as the worst election-related violence and the most brutal killing of
journalists in recent history, the tragic incident which came to be known as the
Maguindanao Massacre spawned charges for 57 counts of murder and an
additional charge of rebellion against 197 accused, docketed as Criminal Case Nos.
Q-09-162148-72, Q-09-162216-31, Q-10-162652-66, and Q-10-163766,
commonly entitled People v. Datu Andal Ampatuan, Jr., et al. Following the
transfer of venue and the reraffling of the cases, the cases are being tried by
Presiding Judge Jocelyn Solis-Reyes of Branch 221 of the Regional Trial Court
(RTC) of Quezon City inside Camp Bagong Diwa in Taguig City.
Almost a year later or on November 19, 2010, the National Union of
Journalists of the Philippines (NUJP), ABS-CBN Broadcasting Corporation, GMA
Network, Inc., relatives of the victims,[1] individual journalists[2] from various
media entities, and members of the academe [3] filed a petition before this Court
praying that live television and radio coverage of the trial in these criminal cases
be allowed, recording devices (e.g., still cameras, tape recorders) be permitted
inside the courtroom to assist the working journalists, and reasonable guidelines be
formulated to govern the broadcast coverage and the use of devices. [4] The Court
docketed the petition as A.M. No. 10-11-5-SC.
In a related move, the National Press Club of the Philippines [5] (NPC)
and Alyansa ng Filipinong Mamamahayag[6](AFIMA) filed on November 22,

2010 a petition praying that the Court constitute Branch 221 of RTC-Quezon City
as a special court to focus only on the Maguindanao Massacre trial to relieve it
of all other pending cases and assigned duties, and allow the installation inside the
courtroom of a sufficient number of video cameras that shall beam the audio and
video signals to the television monitors outside the court. [7] The Court docketed
the petition as A.M. No. 10-11-6-SC.

President Benigno S. Aquino III, by letter of November 22,

2010 addressed to Chief Justice Renato Corona, came out in support of those
who have petitioned [this Court] to permit television and radio broadcast of the
trial." The President expressed earnest hope that [this Court] will, within the
many considerations that enter into such a historic deliberation,attend to this
petition with the dispatch, dispassion and humaneness, such a petition
merits.[9] The Court docketed the matter asA.M. No. 10-11-7-SC.
[8]

By
separate
Resolutions
of
November
23,
2010, [10] the
Court consolidated A.M. No. 10-11-7-SC with A.M. No. 10-11-5-SC. The Court
shall treat in a separate Resolution A.M. No. 10-11-6-SC.
Meanwhile, various groups[11] also sent to the Chief Justice their respective
resolutions and statements bearing on these matters.
The principal accused in the cases, Andal Ampatuan, Jr. (Ampatuan), filed a
Consolidated Comment of December 6, 2010 in A.M. No. 10-11-5-SC and A.M.
No. 10-11-7-SC. The President, through the Office of the Solicitor General (OSG),
and NUJP, et al. filed their respective Reply of January 18, 2011 and January 20,
2011. Ampatuan also filed a Rejoinder of March 9, 2011.
On Broadcasting the Trial of the Maguindanao Massacre Cases
Petitioners seek the lifting of the absolute ban on live television and radio
coverage of court proceedings. They principally urge the Court to revisit
the 1991 ruling in Re: Live TV and Radio Coverage of the Hearing of President
Corazon C. Aquinos Libel Case[12] and the 2001 ruling in Re: Request Radio-TV
Coverage of the Trial in the Sandiganbayan of the Plunder Cases Against the
Former President Joseph E. Estrada[13] which rulings, they contend, violate the
doctrine that proposed restrictions on constitutional rights are to be narrowly
construed and outright prohibition cannot stand when regulation is a viable
alternative.
Petitioners state that the trial of the Maguindanao Massacre cases has
attracted intense media coverage due to the gruesomeness of the crime,
prominence of the accused, and the number of media personnel killed. They

inform that reporters are being frisked and searched for cameras, recorders, and
cellular devices upon entry, and that under strict orders of the trial court against
live broadcast coverage, the number of media practitioners allowed inside the
courtroom has been limited to one reporter for each media institution.
The record shows that NUJP Vice-Chairperson Jose Jaime Espina, by
January 12, 2010 letter[14] to Judge Solis-Reyes, requested a dialogue to discuss
concerns over media coverage of the proceedings of the Maguindanao Massacre
cases. Judge Solis-Reyes replied, however, that matters concerning media
coverage should be brought to the Courts attention through appropriate
motion.[15] Hence, the present petitions which assert the exercise of the freedom
of the press, right to information, right to a fair and public trial, right to assembly
and to petition the government for redress of grievances, right of free access to
courts, and freedom of association, subject to regulations to be issued by the Court.
The Court partially GRANTS pro hac vice petitioners prayer for a live
broadcast of the trial court proceedings,subject to the guidelines which shall be
enumerated shortly.
Putts Law[16] states that technology is dominated by two types of people:
those who understand what they do not manage, and those who manage what they
do not understand. Indeed, members of this Court cannot strip their judicial robe
and don the experts gown, so to speak, in a pretense to foresee and fathom all
serious prejudices or risks from the use of technology inside the courtroom.
A decade after Estrada and a score after Aquino, the Court is once again
faced with the same task of striking that delicate balance between seemingly
competing yet certainly complementary rights.
The indication of serious risks posed by live media coverage to the
accuseds right to due process, left unexplained and unexplored in the era obtaining
in Aquino and Estrada, has left a blow to the exercise of press freedom and the
right to public information.
The rationale for an outright total prohibition was shrouded, as it is
now, inside the comfortable cocoon of a feared speculation which no scientific

study in the Philippine setting confirms, and which fear, if any, may be dealt
with by safeguards and safety nets under existing rules and exacting
regulations.
In this day and age, it is about time to craft a win-win situation that
shall not compromise rights in the criminal administration of justice, sacrifice press
freedom and allied rights, and interfere with the integrity, dignity and solemnity of
judicial proceedings. Compliance with regulations, not curtailment of a right,
provides a workable solution to the concerns raised in these administrative matters,
while, at the same time, maintaining the same underlying principles upheld in the
two previous cases.
The basic principle upheld in Aquino is firm [a] trial of any kind or in any
court is a matter of serious importance to all concerned and should not be treated as
a means of entertainment[, and t]o so treat it deprives the court of the dignity
which pertains to it and departs from the orderly and serious quest for truth for
which our judicial proceedings are formulated. The observation that [m]assive
intrusion of representatives of the news media into the trial itself can so alter and
destroy the constitutionally necessary atmosphere and decorum stands.
The Court concluded in Aquino:
Considering the prejudice it poses to the defendant's right to due process as
well as to the fair and orderly administration of justice, and considering further
that the freedom of the press and the right of the people to information may be
served and satisfied by less distracting, degrading and prejudicial means, live radio
and television coverage of court proceedings shall not be allowed. Video footages
of court hearings for news purposes shall be restricted and limited to shots of the
courtroom, the judicial officers, the parties and their counsel taken prior to the
commencement of official proceedings. No video shots or photographs shall be
permitted during the trial proper.
Accordingly, in order to protect the parties' right to due process, to prevent
the distraction of the participants in the proceedings and in the last analysis, to
avoid miscarriage of justice, the Court resolved to PROHlBIT live radio and
television coverage of court proceedings. Video footage of court hearings for news
purposes shall be limited and restricted as above indicated.[17]

The Court had another unique opportunity in Estrada to revisit the question
of live radio and television coverage of court proceedings in a criminal case. It
held that [t]he propriety of granting or denying the instant petition involve[s] the
weighing out of the constitutional guarantees of freedom of the press and the right
to public information, on the one hand, and the fundamental rights of the accused,
on the other hand, along with the constitutional power of a court to control its
proceedings in ensuring a fair and impartial trial. The Court disposed:
The Court is not all that unmindful of recent technological and scientific
advances but to chance forthwith the life or liberty of any person in a hasty bid to
use and apply them, even before ample safety nets are provided and the concerns
heretofore expressed are aptly addressed, is a price too high to pay.
WHEREFORE, the petition is DENIED.
SO ORDERED.[18]

In resolving the motion for reconsideration, the Court in Estrada, by

Resolution of September 13, 2001, provided a glimmer of hope when it ordered the
audio-visual recording of the trial for documentary purposes, under the following
conditions:
x x x (a) the trial shall be recorded in its entirety, excepting such portions
thereof as the Sandiganbayan may determine should not be held public under Rule
119, 21 of the Rules of Criminal Procedure; (b) cameras shall be installed
inconspicuously inside the courtroom and the movement of TV crews shall be
regulated consistent with the dignity and solemnity of the proceedings; (c) the
audio-visual recordings shall be made for documentary purposes only and shall be
made without comment except such annotations of scenes depicted therein as may
be necessary to explain them; (d) the live broadcast of the recordings before the
Sandiganbayan shall have rendered its decision in all the cases against the former
President shall be prohibited under pain of contempt of court and other sanctions
in case of violations of the prohibition; (e) to ensure that the conditions are
observed, the audio-visual recording of the proceedings shall be made under the
supervision and control of the Sandiganbayan or its Division concerned and shall
be made pursuant to rules promulgated by it; and (f) simultaneously with the
release of the audio-visual recordings for public broadcast, the original thereof
shall be deposited in the National Museum and the Records Management and
Archives Office for preservation and exhibition in accordance with law.[19]

Petitioners
note
that
the
1965
case
of Estes
v.
Texas which Aquino and Estrada heavily cited, was borne out of the dynamics of
a jury system, where the considerations for the possible infringement of the
impartiality of a jury, whose members are not necessarily schooled in the law, are
different from that of a judge who is versed with the rules of evidence. To
petitioners, Estes also does not represent the most contemporary position of
the United States in the wake of latest jurisprudence[21] and statistical figures
revealing that as of 2007 all 50 states, except the District of Columbia, allow
television coverage with varying degrees of openness.
[20]

Other jurisdictions welcome the idea of media coverage. Almost all the
proceedings of United Kingdoms Supreme Court are filmed, and sometimes
broadcast.[22] The International Criminal Court broadcasts its proceedings via
video streaming in the internet.[23]
On the media coverages influence on judges, counsels and witnesses,
petitioners point out that Aquino and Estrada, likeEstes, lack empirical evidence to
support the sustained conclusion. They point out errors of generalization where the
conclusion has been mostly supported by studies on American attitudes, as there
has been no authoritative study on the particular matter dealing with Filipinos.
Respecting the possible influence of media coverage on the impartiality of
trial court judges, petitioners correctly explain that prejudicial publicity insofar as
it undermines the right to a fair trial must pass the totality of
circumstances test, applied inPeople v. Teehankee, Jr.[24] and Estrada v. Desierto,
[25]
that the right of an accused to a fair trial is not incompatible to a free press, that
pervasive publicity is not per se prejudicial to the right of an accused to a fair trial,
and that there must be allegation and proof of the impaired capacity of a judge to
render a bias-free decision. Mere fear of possible undue influence is not
tantamount to actual prejudice resulting in the deprivation of the right to a fair
trial.
Moreover, an aggrieved party has ample legal remedies. He may challenge
the validity of an adverse judgment arising from a proceeding that transgressed a
constitutional right. As pointed out by petitioners, an aggrieved party may early on
move for a change of venue, for continuance until the prejudice from publicity is

abated, for disqualification of the judge, and for closure of portions of the trial
when necessary. The trial court may likewise exercise its power of contempt and
issue gag orders.
One apparent circumstance that sets the Maguindanao Massacre cases apart
from the earlier cases is the impossibility of accommodating even the parties to the
cases the private complainants/families of the victims and other witnesses
inside the courtroom. On public trial, Estrada basically discusses:
An accused has a right to a public trial but it is a right that belongs to him,
more than anyone else, where his life or liberty can be held critically in balance. A
public trial aims to ensure that he is fairly dealt with and would not be unjustly
condemned and that his rights are not compromised in secrete conclaves of long
ago. A public trial is not synonymous with publicized trial; it only implies that the
court doors must be open to those who wish to come, sit in the available seats,
conduct themselves with decorum and observe the trial process. In the
constitutional sense, a courtroom should have enough facilities for a reasonable
number of the public to observe the proceedings, not too small as to render the
openness negligible and not too large as to distract the trial participants from their
proper functions, who shall then be totally free to report what they have observed
during the proceedings.[26] (underscoring supplied)

Even before considering what is a reasonable number of the public who

may observe the proceedings, the peculiarity of the subject criminal cases is that
the proceedings already necessarily entail the presence of hundreds of families. It
cannot be gainsaid that the families of the 57 victims and of the 197 accused have
as much interest, beyond mere curiosity, to attend or monitor the proceedings as
those of the impleaded parties or trial participants. It bears noting at this juncture
that the prosecution and the defense have listed more than 200 witnesses each.

The impossibility of holding such judicial proceedings in a courtroom that

will accommodate all the interested parties, whether private complainants or
accused, is unfortunate enough. What more if the right itself commands that a
reasonable number of the general public be allowed to witness the proceeding as it
takes place inside the courtroom. Technology tends to provide the only solution to

break the inherent limitations of the courtroom, to satisfy the imperative of

a transparent, open and public trial.
In so allowing pro hac vice the live broadcasting by radio and television of
the Maguindanao Massacre cases,
the
Court
lays down the
following guidelines toward
addressing
the
concerns
mentioned
in Aquino and Estrada:
(a) An audio-visual recording of the Maguindanao massacre cases may
be made both for documentary purposes and for transmittal to live
radio and television broadcasting.
(b) Media entities must file with the trial court a letter of application,
manifesting that they intend to broadcast the audio-visual recording of
the proceedings and that they have the necessary technological
equipment and technical plan to carry out the same, with an
undertaking that they will faithfully comply with the guidelines and
regulations and cover the entire remaining proceedings until
promulgation of judgment.
No selective or partial coverage shall be allowed. No media
entity shall be allowed to broadcast the proceedings without an
application duly approved by the trial court.
(c) A single fixed compact camera shall be installed inconspicuously
inside the courtroom to provide a single wide-angle full-view of the
sala of the trial court. No panning and zooming shall be allowed to
avoid unduly highlighting or downplaying incidents in the
proceedings. The camera and the necessary equipment shall be
operated and controlled only by a duly designated official or employee
of the Supreme Court. The camera equipment should not produce or
beam any distracting sound or light rays. Signal lights or signs
showing the equipment is operating should not be visible. A limited
number of microphones and the least installation of wiring, if not
wireless technology, must be unobtrusively located in places indicated
by the trial court.

The Public Information Office and the Office of the Court

Administrator shall coordinate and assist the trial court on the physical
set-up of the camera and equipment.
(d) The transmittal of the audio-visual recording from inside the
courtroom to the media entities shall be conducted in such a way that
the least physical disturbance shall be ensured in keeping with the
dignity and solemnity of the proceedings and the exclusivity of the
access to the media entities.
The hardware for establishing an interconnection or link with
the camera equipment monitoring the proceedings shall be for the
account of the media entities, which should employ technology that
can (i) avoid the cumbersome snaking cables inside the courtroom, (ii)
minimize the unnecessary ingress or egress of technicians, and (iii)
preclude undue commotion in case of technical glitches.
If the premises outside the courtroom lack space for the set-up
of the media entities facilities, the media entities shall access the
audio-visual recording either via wireless technology accessible even
from outside the court premises or from one common web
broadcasting platform from which streaming can be accessed or
derived to feed the images and sounds.
At all times, exclusive access by the media entities to the realtime audio-visual recording should be protected or encrypted.
(e) The broadcasting of the proceedings for a particular day must be
continuous and in its entirety, excepting such portions thereof where
Sec. 21 of Rule 119 of the Rules of Court [27] applies, and where the
trial court excludes, upon motion, prospective witnesses from the
courtroom, in instances where, inter alia, there are unresolved
identification issues or there are issues which involve the security of
the witnesses and the integrity of their testimony (e.g., the dovetailing
of corroborative testimonies is material, minority of the witness).
The trial court may, with the consent of the parties, order only
the pixelization of the image of the witness or mute the audio output,
or both.

(f) To provide a faithful and complete broadcast of the proceedings, no

commercial break or any other gap shall be allowed until the days
proceedings are adjourned, except during the period of recess called by
the trial court and during portions of the proceedings wherein the
public is ordered excluded.
(g) To avoid overriding or superimposing the audio output from the
on-going proceedings, the proceedings shall be broadcast without any
voice-overs, except brief annotations of scenes depicted therein as may
be necessary to explain them at the start or at the end of the
scene. Any commentary shall observe the sub judice rule and be
subject to the contempt power of the court;
(h) No repeat airing of the audio-visual recording shall be allowed
until after the finality of judgment, except brief footages and still
images derived from or cartographic sketches of scenes based on the
recording, only for news purposes, which shall likewise observe
the sub judice rule and be subject to the contempt power of the court;
(i) The original audio-recording shall be deposited in
the National Museum and the Records Management and Archives
Office for preservation and exhibition in accordance with law.
(j) The audio-visual recording of the proceedings shall be made under
the supervision and control of the trial court which may issue
supplementary directives, as the exigency requires, including the
suspension or revocation of the grant of application by the media
entities.

(k) The Court shall create a special committee which shall forthwith
study, design and recommend appropriate arrangements, implementing
regulations, and administrative matters referred to it by the Court
concerning the live broadcast of the proceedings pro hac vice, in
accordance with the above-outlined guidelines. The Special
Committee shall also report and recommend on the feasibility,

availability and affordability of the latest technology that would meet

the herein requirements. It may conduct consultations with resource
persons and experts in the field of information and communication
technology.
(l) All other present directives in the conduct of the proceedings of the
trial court (i.e., prohibition on recording devices such as still cameras,
tape recorders; and allowable number of media practitioners inside the
courtroom) shall be observed in addition to these guidelines.
Indeed, the Court cannot gloss over what advances technology has to offer in
distilling the abstract discussion of key constitutional precepts into the workable
context. Technology per se has always been neutral. It is the use and regulation
thereof that need fine-tuning. Law and technology can work to the advantage and
furtherance of the various rights herein involved, within the contours of defined
guidelines.
WHEREFORE, in light of the foregoing disquisition, the
Court PARTIALLY GRANTS PRO HAC VICE the request for live broadcast by
television and radio of the trial court proceedings of the Maguindanao Massacre
cases, subject to the guidelines herein outlined.
SO ORDERED.
CONCHITA CARPIO MORALES
Associate Justice

WE CONCUR:

(ON OFFICIAL LEAVE)

RENATO C. CORONA
Chief Justice

ANTONIO T. CARPIO
Associate Justice

PRESBITERO J. VELASCO, JR.

Associate Justice

TERESITA J. LEONARDO-DE CASTRO

Associate Justice

ARTURO D. BRION
Associate Justice

DIOSDADO M. PERALTA
Associate Justice

LUCAS P. BERSAMIN
Associate Justice

MARIANO C. DEL CASTILLO

Associate Justice

ROBERTO A. ABAD
Associate Justice

MARTIN S. VILLARAMA, JR.

Associate Justice

JOSE PORTUGAL PEREZ

Associate Justice

JOSE CATRAL MENDOZA

Associate Justice

*
[1]
[2]

[3]

[4]
[5]
[6]
[7]
[8]
[9]
[10]
[11]

[12]
[13]
[14]
[15]
[16]

[17]
[18]
[19]
[20]
[21]

MARIA LOURDES P. A.
SERENOAssociate Justice

On official leave.
Ma. Reynafe Momay-Castillo, Editha Mirandilla-Tiamzon, and Glenna Legarta.
Horacio Severino, Glenda Gloria, Mariquit Almario Gonzales, Arlene Burgos, Abraham Balabad, Jr., Joy
Gruta, Ma. Salvacion Varona, Isagani De Castro, Danilo Lucas, Cecilia Victoria Orena Drilon, Cecilia
Lardizabal, Vergel Santos, Romula Marinas, Noel Angel Alamar, Joseph Alwyn Alburo, Rowena Paraan,
Ma. Cristina Rodriguez, Luisita Cruz Valdes, David Jude Sta. Ana, and Joan Bondoc.
Roland Tolentino, Danilo Arao, Elena Pernia, Elizabeth Enriquez, Daphne Tatiana Canlas, Rosalina
Yokomori, Marinela Aseron, Melba Estonilo, Lourdes Portus, Josefina Santos, and Yumina Francisco,
Vide rollo (A.M. No. 10-11-5-SC), p. 95.
Represented by its president, Jerry Yap.
Represented by its president, Benny Antiporda.
Vide rollo (A.M. No. 10-11-6-SC), p. 19.
Rollo (A.M. No. 10-11-7-SC), pp. 1-2.
Id. at 2.
Rollo (A.M. No. 10-11-7-SC), p. 3; rollo (A.M. No. 10-11-5-SC), p. 186.
The Sangguniang Panlungsod of General Santos City endorsed Resolution No. 484 of November 22,
2010 which resolved to strongly urge the Supreme Court of thePhilippines to allow a live media coverage
for public viewing and information on the court proceedings/trial of the multiple murder case filed against
the suspects of the Maguindanao massacre. The Court noted it by Resolution of December 14,
2010. Rollo, (A.M. No. 10-11-5-SC), pp. 429-431, 434.
The Integrated Bar of the Philippines (IBP) Cebu City Chapter passed Resolution No. 24 (December 7,
2010) which resolved, inter alia, respectfully ask the Supreme Court to issue a circular or order to allow
Judge Jocelyn Solis-Reyes to concentrate on the case of the Maguindanao massacre, unencumbered by
other cases until final decision in this case is rendered. The Court noted it by Resolution of January 18,
2011. Rollo, (A.M. No. 10-11-6-SC), pp. 90-91, 97.
The Sangguniang Panlungsod of Cagayan de Oro City also carried Resolution Nos. 10342-2010 and
10343-2010, both dated November 23, 2010, which resolved to support the clamor for speedy trial and
that the hearing of the Maguindanao massacre be made public with a request to consider the appeal to
air live the hearings thereof. The Court noted it by Resolution of December February 1, 2011. Rollo,
(A.M. No. 10-11-5-SC), pp. 671-674, 676.
En Banc Resolution of October 22, 1991.
A.M. No. 01-4-03-SC, June 29, 2001, 360 SCRA 248; Perez v. Estrada, 412 Phil. 686 (2001).
Rollo, (A.M. No. 10-11-5-SC), p. 121.
Id. at 122.
Based on the 1981 book entitled Putts Law and the Successful Technocrat which is attributed to the
pseudonym Archibald Putt.
Supra note 20 at 6-7.
Perez v. Estrada, 412 Phil. 686, 711.
A.M. No. 01-4-03-SC, September 13, 2001, 365 SCRA 62, 70.
381 U.S. 532 (1965).
Chandler v. Florida, 449 U.S. 560 (1981).

[22]
[23]
[24]
[25]
[26]
[27]

<http://www.supremecourt.gov.uk/about/did-you-know.html> (Last accessed: May 25, 2011).

Vide <http://livestream.xs4all.nl/icc1.asx> (Last accessed: June 7, 2011).
G.R. Nos. 111206-08, October 6, 1995, 249 SCRA 54.
G.R. Nos. 146710-15, March 2, 2001, 353 SCRA 452.
Perez v. Estrada, supra note 26 at 706-707.
Exclusion of the public. The judge may, motu proprio, exclude the public from the courtroom if the
evidence to be produced during the trial is offensive to decency or public morals. He may also, on motion
of the accused, exclude the public from the trial except court personnel and the counsel of the parties.